24 July, 2018

Wildlife Licensing Reforms Office of Environment and Heritage

Dear Sir or Madam,

Re: Wildlife licensing changes: Public consultation

Thank you for the opportunity to comment on the proposed wildlife licencing changes. As the oldest museum in , the has a long-standing involvement in wildlife licencing both as a licensee and as a recipient of specimens from licence-holders. The Australian Museum is an active stakeholder in biodiversity conservation and through our Australian Centre for Wildlife Genomics’ accreditation as a Wildlife Forensics laboratory, is an authority on the wildlife trade. By world standards, Australia has a relatively high level of regulation of native fauna and the Museum is a keen supporter of this approach. Trade, husbandry and control of native wildlife presents risks in terms of poaching, disease, genetic disruption and establishment of wild populations outside of natural ranges. Although it is costly to implement, we believe that rigorous licensing is an essential element of our conservation strategy and have previously worked with Office of Environment and Heritage on research of kept under license where illegal trade occurred in particular during periods of ad-hoc record keeping (see Hogg et al, 2018). We acknowledge that increasing interest in Australian wildlife has increased the number of people seeking to keep wildlife and it appears that this increase is one of the drivers for this discussion paper. However, we do not agree that expanding the industry should be considered inevitable, nor do we consider it desirable to simplify regulation through codes of practice. Ultimately, we think it is important for government to recognise that licensing is an important function of government and that adequate resourcing must be provided to reflect changes in demand. While we support a risk-management approach in the amount of attention the Department gives to processing licenses with different risk levels, we consider that licensing is a more effective way of curbing growth in the wildlife trade than self-regulation through a code-of- practice approach, which are rarely successful in any industry.

We have a series of specific comments below and also comments in relation to specific species (attachment 1).

Section 2.3  Should licensing be retained for all activities currently requiring a threatened species licence?

We strongly support licensing for all activities involving management of listed threatened species. Grey-headed Flying-foxes (GHFFs) are a listed Vulnerable species and requests for local management must be carefully evaluated. We consider that licensing should be retained for management of flying-foxes in public places unless provisions for “camp managers” in the proposed code of practice are strengthened in two areas. Firstly “camp managers” should not be permitted to commence management until they have had a response from the Environment Agency Head, following notification. It is not sufficient merely to inform the Minister and wait 3 days before proceeding. A response should be mandatory prior to commencement of any activity. Secondly, a panel of “flying-fox experts” should be accredited by the Environment Agency and only the panel of accredited experts should be permitted to advise camp managers. We acknowledge that the current process of camp management is narrow-sighted with focus on any one particular camp site at a time. Dispersal actions often lead to shifting the problem to other sites (and councils), rather than looking for a more holistic approach. Therefore, the identified steps in the process of “studying a camp” to “assessing impacts of actions” have to be done in consultation with these accredited “flying-fox experts”. As they stand, the criteria for defining an expert leave too much room for insufficiently-skilled operators. The effect of these two weaknesses in the proposed arrangements make it possible for public land managers to have significant negative impacts on this threatened species. Unless these are rectified, we consider that licensing should remain, and recommend that further strict monitoring of each step in the management process must be in place to ensure compliance with ethics regulations. Further regular public reporting on dispersal sites should be enforced to ensure that there is a measure of ‘success’ of such actions for future planning.

In addition, shooting of flying-foxes in orchards requires continued licensing, but also ensuring improved regulation and monitoring. While the overall number of licenses issued appears to have decreased (e.g. 15 during 2016/17 season vs, 34 during 2006/7 season), the number of allowed to be harmed was actually 30% greater (3728 vs 1155). There has been an inherent issue with non-compliance in the past: high proportion of orchardists have been reported as shooting without a license or outside license provisions, and the methods are often in contravention of animal ethics, leaving injured animals to suffer for hours before death. The current practice of reporting the numbers of harmed GHFFs is inadequate and we acknowledge that the available resources for adequate monitoring of compliance with license are inadequate and need to be revised.

Section 4.2.2 • Do you support the retention of licensing for harming protected ? We consider that licensing provides a higher level of protection for protected species than a code of practice, and there is considerable potential for this change to increase the level of destruction of native species. We therefore support the retention of licensing.

• Can you suggest any improvements to the licence conditions for harming birds? As it stands, there is considerable ambiguity in the activities that can be undertaken under a licence to harm protected birds. The nominated purposes all refer to damage mitigation associated with human activities, but the list of species harmed includes species that appear to have been killed for other reasons. For example, Table 7 indicates that 3572 Noisy Miners were harmed in 2017, but this species does not threaten human safety or property. Presumably, these licences have been issued for culling for conservation purposes associated with the Noisy Miner KTP, but this is not provided for in the current wording of the licence. There are many other situations (including macropod grazing pressure) where overabundant native species have adverse ecological impacts, rather than impacts on human safety and property, and there should be a license class that allows management of these impacts. We therefore recommend broadening the description of this class of licence to explicitly include ecological management activities, especially since it appears that some licences have already been issued for this purpose. It is our understanding that as presently described, the only explicit provision for ecological culls is through a scientific licence, which requires evaluation by an animal ethics committee. Such a process is both unnecessary and prohibitive for most land managers. We consider it a priority for licence conditions to be changed to ensure that these management options are available under the Act.

• Should codes of practice be developed for harming birds in specified circumstances as an alternative to licensing? We do not support the replacement of licensing with codes of practice, because we think it will result in an increase in animal deaths, usually with little or no benefit. The suggested example of “removal of white ibis nests and from public parks by councils” provides a good test case. If provided with a code of practice, Councils will be encouraged to routinely employ this tool without due consideration of non-destructive alternatives, or alternatives that require licensing. It is usually just a few ibis (the table-jumpers/sandwich-snatchers) that cause problems for people, and the most cost effective, humane and ecologically-sound method of dealing with that problem is to catch and kill the offending animal. Park managers do not tend to employ this option because they are concerned about public backlash or the difficulty of obtaining a licence.

Instead, to appease park-users, they remove nests and eggs either from misunderstanding of its efficacy or simply to be seen to be doing something which people incorrectly do not perceive to be as ecologically damaging as culling adults. Ibis sometimes present a problem by nesting close to human habitation, and nest and destructive may occasionally be effective in causing ibis to vacate these sites. However, ibis usually re-nest in the same location following destruction of their nests and eggs and sustained removal every three weeks is usually necessary to discourage re-nesting. It is our experience that land-managers normally give up before the ibis. modification in the form of trimming, or sometimes removing, nesting substrates is generally a more effective technique for discouraging nesting. The requirement to be licensed acts as an incentive for park managers to consider the specific problem they seek to address and the options for resolving it. We consider that providing the option of an unlicensed code-of-practice will encourage an ineffective one-size-fits-all approach that will lead to unnecessary ecological harm. While we have addressed only the white ibis example, the same logic applies to other wildlife issues.

Section 5.1 • Do you support the proposed staged approach to implementing a risk-based approach to regulating native animal keeping? The Australian Museum is committed to the conservation of native animals in their natural and considers that the wildlife trade presents risks to native populations from poaching, spread of disease, establishment of species outside of their range and genetic disruption. Australian species, in particular birds and are very popular in the illegal wildlife trade and can command significant prices overseas. By not regulating wildlife keeping in NSW it enables a leaky system whereby unregulated keeping can feed the illegal trade in these species. Our position is that both the number of wildlife keepers and the number of species traded and kept in captivity should be minimized, thus minimizing any legal loopholes enabling the illegal wildlife trade. We do not support continued growth of the wildlife trade and consequently we do not support policy designed to simplify the trade. We consider that licensing is the preferred option for controlling the trade do not support a risk-based approach based on codes of practice.

The Australian Centre for Wildlife Genomics (ACWG) can also provide the example of Hoplocephalus bungaroides (broad-headed ). This species can be kept with the appropriate license. However, it was suspected that animals were being illegally obtained from the wild and passed off as licensed animals that had died, or as offspring of licensed animals. Research carried out by the ACWG, found that the privately kept animals which should have been a genetically closed population, overlapped with wild caught animals suggesting recent introduction of wild genes into the captive population. This has likely occurred through inconsistent record keeping and licensed regulation. The ACWG therefore advocates for a)

licensing to be continued with the appropriate resources to keep track of all keepers and b) the establishment of genetic biobanks of high risk (eg. high risk of illegal trade) species, whereby genetic material is bio banked as part of the licensing process, providing a robust method for validating claims of provenance and parentage and stamp out the illegal trade.

Whilst there may be some benefits to keeping some native species as pets (in terms of people having a connection to native wildlife), the risk posed by removing licensing and likely increasing the volume of animals and species kept as pets is likely to increase the threat to wild populations of native species. Deregulation is also likely to facilitate, via releases and escapes, the establishment of populations outside their native ranges with uncertain ecological consequences. This is already an issue with species of birds, frogs reptiles and and will be exacerbated by the proposed licensing changes.

While popularity of species wax and wane, for species where there is a known demand in the wildlife trade, more advanced/restricted licenses should be required, with this list of species regularly reviewed.

• Do you support a risk-based approach to annual records for licensed keepers including simplified returns for Class 1 and advanced keepers, but retention of current animal record book requirements for keepers of venomous ? We do not consider that the risk presented to animal keepers is the appropriate currency for evaluating a “risk-based approach” to licensing. The mandate of the Office of Environment and Heritage is to protect the flora and fauna of the state, and so any risk assessment should be evaluated in terms of conservation risk. Accordingly, we do not support the proposed risk-based approach because the degree to which a species is venomous is not a relevant criterion.

Section 5.2 Do you support the retention of licensing for pet shops that sell native animals and expanding the list of species they may sell? We do not recommend expanding the list of native species pet shops may sell for reasons outlined in the general comments section above.

Section 5.4 Do you support the retention of licensing for taxidermists to enable effective monitoring of the sources of preserved native animals? We do support the retention of licensing for taxidermists in order to effectively monitor the source of these animals and to reduce the likelihood that these specimens will become part of the illegal trade in wildlife products.

Can you suggest any changes or improvements to the license conditions and reporting requirements for licensed taxidermists? We recommend that firstly, records of preserved specimens held by taxidermists should contain detailed information as to the source of the animal. If from road kill, then the exact location and date collected should be recorded. If sourced from a keeper or wildlife park, the record should show the individual animal’s unique identification number. Secondly, any person found guilty of a wildlife related offence should not be granted a license or if they have an existing license, this license should be cancelled. Thirdly, that the holding of preserved specimens (other than carved Emu eggs or lawfully killed animals) is NOT exempted from the offence of possessing under the BC regulation for reasons stated in the general comments section above.

Section 6.2 • Do you have any suggestions to simplify the conditions for scientific licences? The Australian Museum supports the need for scientific licences and their considered evaluation. However, the present system is unsatisfactory in that there is an unreasonable delay in processing that is not compatible with the time-frame of research projects (e.g. enlisting the research effort of students). We are unaware of the cause of this delay but suspect it is due to shortage of staff with the skills to evaluate licences. In rare cases, applications will need the input of specialists, but most licences should be able to be evaluated by trained staff in the licensing office without the need for specialist review. It appears that while the number of scientific licences has been growing, the resourcing provided to the Licensing section has declined. Licensing is a necessary function of government and the resources must be made available to ensure that licenses are assessed and issued in a timely manner.

Section 7.3 • Do you have any suggestions to improve fairness and equity in setting licence fees? We do not think the proposed licence fees for scientific licences are equitable. Scientific research serves a public benefit and, in many cases provides the scientific knowledge required by the Environment Agency to fulfil its charter. Accordingly, there should be no fee for scientific licences, or at least a discretionary clause should be included to allow fees to be waived when it is deemed that the research will benefit the Agency. The current proposal is particularly inequitable given that no fee is proposed for damage mitigation licences which generally confer a private benefit.

Additional comments: The Australian Museum’s charter requires it to build and maintain collections of native fauna. An increasingly important source of specimens for the Museum’s collections is road kill. The current legislation makes it technically illegal for members of the public to collect road kill and transport it

to the Museum. In the interests of clarity and protection for the community, we recommend the development of a code of practice which permits citizens to collect and hold dead animals for a limited period. Such a code should include a provision for timely notification of an authority (Environmental Agency or Australian Museum) of a potential specimen coming into their care. This review presents the opportunity to ensure that specimens and samples collected under scientific and other licenses in NSW be required to be offered to the Australian Museum upon completion of the project/end of the license. Just as current requirements are to ad records to The NSW Wildlife Atlas so should it be a requirement to lodge specimens and samples collected in NSW to the Australian Museum. At present, tissues and genetic samples in particular are collected for many non-Museum research projects in NSW and are not deposited at the Australian Museum or other relevant state institution and so are not available for future research on Australia’s biodiversity.

A further issue for consideration is that NSW DPI animal ethics has criteria for when taking voucher specimens without prior permission (https://www.animalethics.org.au/policies-and- guidelines/wildlife-research/opportunistic-research). However, this is not consistent with current licensing. The Australian Museum would like to encourage the taking of voucher species to anchor distribution records, allow species ID to be confirmed, to buffer against ongoing taxonomic changes and to provide material for continuing taxonomic and genetic research.

Draft Code of Practice for Keeping Native Frogs Disease is a particular concern for frogs, given the devastating impact on wild frog species and populations in Australia (and globally) of the amphibian chytrid fungus-infection. This and other diseases in captive frogs present a significant threat to our native frogs if they are kept outside or released.  Given the risks that captive frogs pose to native frogs in terms of disease transfer, outdoor enclosures should not be allowed.  Disposal of waste material/water from captive frogs should also be considered as it may be infected with diseases infecting frogs and freshwater fishes and reptiles.  There does not appear to be a clear rationale as to why some species are listed as each category. For example, Cyclorana novahollandiae is listed as A1 but the very closely related Cyclorana australis is not. Limnodynastes dumerilii dumerilii is listed as Code but the other subspecies of the species are not. Uperoleia fusca is listed as Code but all related species, including abundant, widespread species in the are not listed. A rationale for each species being listed needs to be decided and applied uniformly.  “Frog chytrid disease” should be referred to as chytridiomycosis  “possibly chytrid infected” should be “possibly infected with the amphibian chytrid fungus”. There are many species of chytrids, so need to be specific.

Draft Code of Practice for Keeping Native Reptiles We have multiple concerns with this document, the proposed changes and associated species lists. In particular, regarding the proposed changes concerning Carpet Pythons. All of these concerns and recommendations are detailed, species-by-species in Attachment 1.

Species lists The species lists associated with this review and any new regulations need to be accurate and up to date. This is currently not the case (please see annotations on the attached spreadsheet). While we acknowledge that keeping up with taxonomic changes is a burden, not doing so has adverse impacts. Not changing in an applied way can assist and promote poaching. When one species is ‘split’ into several new species, keepers may collect the new species if they did not already have them and claim they had them under the old recognised species. It can also lead to confusion, in the current list somebody has applied to add a species to the keepers list, which is already on the approved species list but under old taxonomy.

Please contact me if there is any further information the Museum can supply or if there is any other way in which we could assist deliberations.

Yours faithfully,

Dr Rebecca Johnson Director, Australian Museum Research Institute

Contributors: Dr Mark Eldridge Dr Richard Major Dr Jodi Rowley Dr Sandy Ingleby Dr Anja Divljan Dr Stephen Mahony Dr Greta Frankham

References Hogg, C.J., S. Dennison, G.J. Frankham, M. Hinds, and R.N. Johnson. 2018. Stopping the spin cycle: genetics and bio-banking as a tool for addressing the laundering of illegally caught wildlife as ‘captive-bred’. Conservation Genetics Resources 10: 237-246.

Attachment 1 Scientific Name Common Name Species Code Species Group Current Class Proposed Class Comment AM Proposed Code AM Feedback Comments and Reasoning childreni Children's 2619 Python R1, companion Code Antaresia maculosa Eastern small-blotched python 2818 Python R1, companion Code Chelodina longicollis Eastern snake-necked turtle 2017 Turtle/tortoise R1 companion Code Emydura macquarii Murray short-necked turtle 2034 Turtle/tortoise R1, companion Code bredli Centralian carpet python 2623 Python R1, companion Code R3 In a risk based approach to licensing, I believe the risk of these species has been greatly under-stated. Keeping carpet pythons has three main risk; released captive genetic risk to wild, risk of poor ethical conditions for animals and a large risk of illegal import and poaching. Released Captives: Carpet pythons are one of the most kept snakes, but they are also a very widespread wild species occuring in many instances in suburbs and bushy areas of cities very near humans. Many people have their captive carpet pythons escape, cheyni Jungle carpet python 5094 Python R1, companion Code R3 often due to inexperience keeping. Escaped carpet pythons unlike most other species being kept, are quite likely to escape in a proximity to wild animals they can breed with, spreading disease and potentially weakening wild genetic pools. This is excacerbated by the fact that many different 'subspecies' of Carpet Python are kept from all over Australia, and the prevelance of 'morphs' that are kept. Ethical Considerations: In more recent years a huge abundance of Carpet Python Morelia spilota imbricata Western carpet python 5098 Python R1, companion Code R3 'morphs' have become available. The origin of some of these is dubious and quite possibly from illegal importation. While some of these morphs do not have known health issues, others are known to often suffer terrible health issues including neurological problems. The ethical implications of allowing the prevelance of morphs in the hobby and the continued mass breeding of snakes with potentially very low life quality is an issue which has not been well assessed under the current license. Poaching/Illegal Import: As said above, over the past years the number of 'morphs' Morelia spilota mcdowelli Eastern carpet python 5095 Python R1, companion Code R3 carpet pythons in Australia has sky-rocketed. In a large proportion of cases these morphs originated in the US or elsewhere overseas before 'appearing' in Australia with the keeper claiming a random mutation. The chance that many of these were illegally imported should not be understated and is likely to be a continueing problem. On the other side, Carpet Pythons are a fairly common wild species in proximity to humans. There are already many anectodal cases of people finding wild inviduals and keeping them. This is only likely to increase under relaxed conditions. Morelia spilota metcalfei Murray/darling carpet python 5097 Python R1, companion Code R3

Overall the risk of Carpet Pythons has been wildly understated. I beleive they pose the greatest risk of any current captive species. Keeping of these species should not in any way be made easier, and should in fact be more controlled. I recommend moving them to a scheme similar to that of Elapid keeping in which keepers must ensure cages are absolutely escape proof and potentially with mandatory vet checks to Morelia spilota variegata Top end carpet python 5099 Python R1, companion Code R3 ensure quality of life.

Nephrurus levis levis Smooth knob-tail gecko 2962 Gecko R1 companion Code henrylawsoni Black-soil bearded dragon 2775 Dragon R1, companion Code Pogona vitticeps Central bearded dragon 2204 Dragon R1, companion Code Tiliqua scincoides Common blue-tongue 2580 R1, companion Code Underwoodisaurus milii Thick-tailed gecko 2138 Gecko R1, companion Code Acritoscincus platynota Red-throated cool-skink 2464 Skink R1 R1 muricatus Jacky lashtail 2194 Dragon R1 R1 Amphibolurus nobbi Nobbi lashtail 2195 Dragon R1 R1 Anomalopus brevicollis Short-necked worm-skink 2039 Skink R1 R1 Anomalopus verreauxii Three-clawed worm-skink 2295 Skink R1 R1 Antaresia childreni x maculosa Children's/eastern small-blotched python hybrid T162 Python R1, companion R1, companion Antaresia childreni x stimsoni Children's/Stimson's python hybrid T169 Python R1, companion R1, companion Antaresia perthensis 2622 Python R1, companion R1, companion melanocephalus Black-headed python 2612 Python R1, companion R1, companion Code Aspidites ramsayi Woma 2613 Python R1, companion R1, companion Threatened species (V) Boiga irregularis Eastern brown snake 2630 Colubridae R1 R1 Boiga irregularis fusca Northern brown tree snake T172 Colubridae R1 R1 Brachyurophis australis Eastern shovel-nosed snake 2711 R1 R1 Cacophis krefftii Dwarf crowned snake 2646 Elapidae R1 R1 Cacophis squamulosus Golden crowned snake 2647 Elapidae R1 R1 Chelodina canni snake-necked turtle 2018 Turtle/tortoise R1, companion R1, companion Chelodina oblonga collei Oblong snake-necked turtle 2019 Turtle/tortoise R1, companion R1, companion Chelodina sp. Long-necked turtle species unknown T900 Turtle/tortoise R1 companion R1 companion Christinus marmoratus Marbled southern gecko 2126 Gecko R1 R1 Cryptoblepharus virgatus Cream-striped shining-skink 2331 Skink R1 R1 nuchalis Central netted ground-dragon 2196 Dragon R1 companion R1 companion Ctenophorus pictus Painted ground dragon 2199 Dragon R1 R1 Ctenotus regius Pale-rumped ctenotus 2374 Skink R1 R1 Ctenotus robustus Robust ctenotus 2375 Skink R1 R1 Ctenotus taeniolatus Copper-tailed ctenotus 2386 Skink R1 R1 Cyclodomorphus casuarinae She-oak slender blue-tongue 2574 Skink R1, companion R1, companion Cyclodomorphus gerrardii Pink-tongued skink 2575 Skink R1 companion R1 companion Cyclodomorphus michaeli Mainland she-oak skink 2866 Skink R1, companion R1, companion Delma tincta Excitable delma 2165 Legless R1 R1 psammophis Yellow faced whip snake 2655 Elapidae R1 R1 Dendrelaphis punctulatus Green tree snake 2633 Colubridae R1 R1 Denisonia devisi De vis's banded snake 2660 Elapidae R1 R1 Diplodactylus steindachneri Box-patterned gecko 2071 Gecko R1 R1 Diplodactylus tessellatus Tesselated gecko 2076 Gecko R1 R1 Diplodactylus vittatus Eastern stone gecko 2077 Gecko R1 R1 Diporiphora australis Eastern two-line dragon 223 Dragon R1 R1 Drysdalia coronoides White lipped snake 2665 Elapidae R1 R1 Drysdalia rhodogaster Mustard-bellied snake 2805 Elapidae R1 R1 cunninghami Cunningham's spiny-tailed skink 2408 Skink R1 R1 Egernia Bellatorias frerei 2411 Skink R1 R1 Egernia hosmeri Hosmer's spiny-tailed skink 2412 Skink R1 R1 Egernia Liopholis inornata Unadorned desert-skink 2413 Skink R1 R1 Egernia kingii King's skink 2414 Skink R1 R1 Egernia major Land mullet 2417 Skink R1 R1 Egernia Liopholis modesta Eastern ranges rock-skink 2419 Skink R1 R1 Egernia saxatilis Black crevice-skink 2425 Skink R1 R1 Egernia stokesii Gidgee spiny-tailed skink 2427 Skink R1 R1 Egernia striolata Tree-crevice skink 2429 Skink R1 R1 Egernia Liopholis whitii White's rock skink 2430 Skink R1 R1 Elseya dentata Northern snapping turtle 2028 Turtle/tortoise R1, companion R1, companion Elseya latisternum Saw-shelled turtle 2029 Turtle/tortoise R1, companion R1, companion Elusor macrurus Mary River turtle 2776 Turtle/tortoise R1 companion R1 companion Emydura macquarii dharra Macleay River turtle 2953 Turtle/tortoise R1, companion R1, companion Emydura macquarii dharuk basin turtle 2955 Turtle/tortoise R1, companion R1, companion Emydura macquarii emmotii Copper Creek turtle 2949 Turtle/tortoise R1 companion R1 companion Emydura macquarii gunabarra Hunter River turtle 2954 Turtle/tortoise R1, companion R1, companion Emydura macquarii krefftii Krefft's River turtle 2033 Turtle/tortoise R1, companion R1, companion Emydura macquarii signata Brisbane River short-necked turtle 2035 Turtle/tortoise R1 companion R1 companion Eremiascincus fasciolatus Narrow-banded sand-swimmer 2437 Skink R1 R1 Eremiascincus richardsonii Broad-banded sand-swimmer 2438 Skink R1 R1 Eulamprus murrayi Blue-spectacleD skink 2552 Skink R1, companion R1, companion Eulamprus quoyii Eastern water-skin 2557 Skink R1, companion R1, companion Eulamprus tenuis Bar-sided forest-skink 2559 Skink R1, companion R1, companion Furina diadema Red-naped snake 2669 Elapidae R1 R1 Furina ornata Orange-naped snake 2807 Elapidae R1 R1 Gehyra austrlis Top-end dtella 2085 Gecko R1 R1 Gehyra dubia Dubious dtella 2082 Gecko R1 R1 Gehyra variegata Varied dtella 2092 Gecko R1 R1 Hemiaspis signata Marsh snake 2674 Elapidae R1 R1 Heteronotia binoei Prickly gecko 2105 Gecko R1 R1 Heteronotia spelea Cave prickly gecko 2106 Gecko R1 R1 Hypsilurus spinipes Southern forest dragon 2245 Dragon R1, companion R1, companion Lampropholis delicata Dark-flecked garden sunskink 2450 Skink R1 R1 Lampropholis guichenoti Pale-flecked garden sunskink 2451 Skink R1 R1 Lerista bouganvilii South-eastern slider 2475 Skink R1 R1 Lialis burtonis Burton's snake-lizard 2170 Legless lizard R1 R1 fuscus 2620 Python R1 companion R1 companion Liasis olivaceus 2621 Python R1, companion R1, companion Liasis Antaresia stimsoni Stimson's python 2819 Python R1, companion R1, companion Threatened species (V) Lophognathus Amphibolurus burnsi Burn's dragon 2822 Dragon R1 R1 Lophognathus gilberti Gilbert's lashtail 2246 Dragon R1 R1 Lophognathus Gowidon longirostris Long-snouted lashtail 2247 Dragon R1 R1 Lophognathus Gowidon temporalis Swamplands lashtail 2248 Dragon R1 R1 Lucasium damaeum Beaded gecko 2109 Gecko R1 R1 Macrochelodina rugosa oblonga Northern snake-necked turtle 2020 Turtle/tortoise R1, companion R1, companion Menetia greyii Common dwarf skink 2519 Skink R1 R1 Morelia spilota chenei x spilota variegata Jungle/top end python hybrid T903 Python R1 R1 R3 See above comments on Carpet Pythons. Morelia spilota mcdowelli x Coastal/Centralian carpet python hybrid T164 Python R1, companion R1, companion R3 Morelia spilota mcdowelli x splota chenei Coastal/jungle python hybrid T167 Python R1, companion R1, companion R3 Diamond python 5096 Python R1 companion R1 companion R3 Morelia spilota spilota x Morelia bredli Diamond/Centralian carpet python hybrid T165 Python R1, companion R1, companion R3 Morelia spilota spilota x Morelia cheynei Diamond/jungle python hybrid T170 Python R1, companion R1, companion R3 Morelia spilota spilota x Morelia mcdowelli Carpet/diamond python T171 Python R1 companion R1 companion R3 Morelia spilota spilota x Morelia mcdowelli Diamond/coastal carpet python hybrid T166 Python R1, companion R1, companion R3 Morelia spilota spilota x Morelia metcalfei Diamond/Murray/Darling carpet python hybrid T185 Python R1, companion R1, companion R3 Morelia spilota unknown Carpet/diamond python subspecies unknown 2625 Python R1 companion R1 companion R3 Morethia boulengeri South-eastern morethia skink 2526 Skink R1 R1 Nephrurus amyae Centralian rough knob-tail gecko 2777 Gecko R1, companion R1, companion Nephrurus asper Rough knob-tail gecko 2110 Gecko R1, companion R1, companion Nephrurus laevissimus Smooth knob-tail gecko 2111 Gecko R1, companion R1, companion Nephrurus levis Three-lined knob-tail gecko 2112 Gecko R1, companion R1, companion Nephrurus levis occidentalis 2963 Gecko R1, companion R1, companion Nephrurus levis pilbarensis Smooth knob-tail gecko 2964 Gecko R1, companion R1, companion Nephrurus sheai Kimberley rough knob-tail gecko 2778 Gecko R1, companion R1, companion Nephrurus stellatus Stellate knob-tail gecko 2113 Gecko R1, companion R1, companion Nephrurus wheeleri Banded knob-tail gecko 2115 Gecko R1, companion R1, companion Oedura castelnaui Northern velvet gecko 2116 Gecko R1, companion R1, companion Oedura coggeri Northern spotted velvet gecko 2117 Gecko R1 R1 Oedura filicipoda Fringe-toed velvet gecko 2131 Gecko R1 R1 Oedura Amalosia lesueurii Lesueur's velvet gecko 2118 Gecko R1 R1 Oedura marmorata Marbled velvet gecko 2119 Gecko R1 R1 Oedura monilis Ocellated velvet gecko 2120 Gecko R1 R1 Oedura Nebulifera robusta Robust velvet gecko 2123 Gecko R1 R1 Oedura tryoni Southern spotted velvet gecko 2124 Gecko R1 R1 Parasuta dwyeri Variable black-naped snake 2726 Elapidae R1 R1 Phyllurus platurus Broad-tailed gecko 2129 Gecko R1, companion R1, companion Physignathus lesueurii Eastern water dragon 2252 Dragon R1, companion R1, companion Physignathus lesueurii howitti Gippsland water dragon 5076 Dragon R1 companion R1 companion Physignathus lesueurii lesueurii Eastern water dragon 5075 Dragon R1, companion R1, companion Pogona barbata Eastern bearded dragon 2177 Dragon R1, companion R1, companion Pogona barbata x Pogona vitticeps Eastern/central bearded dragon hybrid T163 Dragon R1 companion R1 companion Pogona minor Western bearded dragon 2191 Dragon R1, companion R1, companion Pogona minima Western bearded dragon 2192 Dragon R1, companion R1, companion Pogona mitchelli North-west bearded dragon 2193 Dragon R1 companion R1 companion Pygopus lepidopodus Southern scaly-foot 2174 Legless lizard R1 R1 Pygopus nigriceps Western scaly-foot 2175 Legless lizard R1 R1 Pygopus schraderi Eastern hooded scaly-foot 2911 Legless lizard R1 R1 Rankinia diemensis Mountain heath dragon 2182 Dragon R1 R1 Saltuarius cornutus Northern leaf-tail gecko 2128 Gecko R1, companion R1, companion Saltuarius salebrosus Rough-throated leaf-tail gecko 2130 Gecko R1, companion R1, companion Saltuarius swaini Southern leaf-tailed gecko 2687 Gecko R1, companion R1, companion Stegonotus cucullatus Slaty-grey snake 2638 Colubridae R1 R1 Strophurus ciliaris Northern spiny-tailed gecko 2053 Gecko R1 R1 Strophurus intermedius Southern-spiny tailed gecko 2059 Gecko R1 R1 Strophurus taenicauda Golden spiny-tailed gecko 2075 Gecko R1, companion R1, companion Strophurus williamsi Eastern spiny-tailed gecko 2078 Gecko R1 R1 Tiliqua nigrolutea Blotched blue-tongue 2578 Skink R1, companion R1, companion Shingleback lizard 2583 Skink R1, companion R1, companion Tiliqua scincoides x Tilique nigrolutea Eastern/blotched blue-tongue hybrid T168 Skink R1, companion R1, companion Varanus acanthurus Ocellate ridge-tailed monitor 2263 Monitor R1 companion R1 companion Varanus gilleni Pygmy mulga monitor 2268 Monitor R1, companion R1, companion Varanus gouldii Sand monitor 2271 Monitor R1, companion R1, companion Varanus tristis Black-tailed monitor 2282 Monitor R1 companion R1 companion Acrochordus arafurae Arafure filesnake 2627 File & blind R2 R2 Carrettochelys insculpta Pig-nosed turtle 2014 Turtle/tortoise R2 R2 Carlia Liburnascincus coensis Coen rainbow-skink 2305 Skink R2 R2 Carphodactylus laevis Chameleon gecko 2046 Gecko R2 R2 Chelodina steindachneri Flat-shelled snake-necked turtle 2021 Turtle/tortoise R2 R2 Chlamydosaurus kingii Frilled lizard 2221 Dragon R2 R2 Ring-tailed bicycle-dragon 2178 Dragon R2 R2 Ctenophorus cristatus Crested bicycle-dragon 2180 Dragon R2 R2 Ctenophorus decresii Tawmy crevice-dragon 2181 Dragon R2 R2 Ctenophorus fionni Peninsula crevice-dragon 2184 Dragon R2 R2 Ctemophorus isolepis Military sand-dragon 2187 Dragon R2 R2 Ctenophorus reticulatus Western netted ground-dragon 2200 Dragon R2 R2 Ctenophorus vadnappa Red-barred crevice-dragon 2203 Dragon R2 R2 Ctenotus leonhardii Leonhardi's ctenotus 2365 Skink R2 R2 Ctenotus pantherinus Leopard ctenotus 2370 Skink R2 R2 Ctenotus pantherinus ocellifer Leopard ctenotus 2993 Skink R2 R2 Threatened species (E) Ctenotus saxatilis Stony-soiled ctenotus 2377 Skink R2 R2 Cyrtodactylus louisiadensis Ring-tailed gecko 2049 Gecko R2 R2 Delma impar Striped legless lizard 2159 Legless lizard R2 R2 Threatened species (V) Delma inornata Patternless delma 2160 Legless lizard R2 R2 Demansia papuensis Greater black whipsnake 2654 Elapidae R2 R2 R3 This is medium-large, very fast, diurnal snake species. Its is potentially serious.

Dendrelaphis calligastra Northern tree snake 2632 Colubridae R2 R2 Diplodactylus byrnei Gibber gecko 2052 Gecko R2 R2 Diplodactylus conspicillatus Fat-tailed diplodactylus 2054 Gecko R2 R2 Diplodactylus elderi Jewelled gecko 2055 Gecko R2 R2 Threatened species (V) Diplodactylus galeatus Helmeted gecko 2057 Gecko R2 R2 Diplodactylus granariensis Wheat-belt stone gecko 2058 Gecko R2 R2 Diplodactylus stenodactylus Crowned gecko 2072 Gecko R2 R2 Threatened species (V) Diporiphora bennettii Robust two-line dragon 2224 Dragon R2 R2 Diporiphora bilineata Northern two-line dragon 2225 Dragon R2 R2 Diporiphora magna Yellow-sided two-line dragon 2229 Dragon R2 R2 Diporiphora winneckei Canegrass two-line dragon 2235 Dragon R2 R2 Egernia depressa Pygmy spiny-tailed skink 2409 Skink R2 R2 Egernia Liopholis margaretae margaretae Centralian Ranges rock-skink 5006 Skink R2 R2 Egernia Liopholis margaretae personata Flinder's Ranges rock-skink 5007 Skink R2 R2 Egernia mcpheei Eastern crevice skink 2213 Skink R2 R2 Egernia Liopholis pulchra South-western rock-skink 2422 Skink R2 R2 Egernia rugosa Yakka skink 2424 Skink R2 R2 Egernia Liopholis striata Nocturnal desert-skink 2428 Skink R2 R2 Elseya albagula Southern snapping turtle 5136 Turtle/tortoise R2 R2 Elseya belli Bell's turtle 2825 Turtle/tortoise R2 R2 Elseya irwini Irwin's turtle 2827 Turtle/tortoise R2 R2 Elseya lavarackorum Gulf snapping turtle 2828 Turtle/tortoise R2 R2 Emydura australis North-west red-faced turtle 2830 Turtle/tortoise R2 R2 Emydura subglobusa Painted short-necked turtle 2036 Turtle/tortoise R2 R2 Emydura tanybaraga Northern yellow-faced turtle 2813 Turtle/tortoise R2 R2 Emydura victoriae Northern red-faced turtle 2037 Turtle/tortoise R2 R2 Enhydris polylepis Macleay's water snake 2634 Colubridae R2 R2 Eulamprus martini Dark barsided skink 2720 Skink R2 R2 Eulamprus tryoni Tryon's skink 2871 Skink R2 R2 Eulamprus tympanum Cool-temperate water-skink 2561 Skink R2 R2 Gehyra montium Centralian dtella 2083 Gecko R2 R2 Gnypetoscincus queenslandiae Prickly forest skink 2584 Skink R2 R2 Hypsilurus Lophosaurus boydii Boyd's forest dragon 2243 Dragon R2 R2 Leiopythn albertisii White-lipped python 2617 Python R2 R2 Lepidodactylus lugubris Mourning chained gecko 2107 Gecko R2 R2 Macrochelodina burrungandjii Sandstone long-necked turtle 2906 Turtle/tortoise R2 R2 Macrochelodina expansa Broad-shelled snake-necked turtle 2016 Turtle/tortoise R2 R2 Morelia amethistina Simalia kinghorni Amethyst python 2618 Python R2 R2 There's a proposal to add this species to the list, but what is on the list as "Morelia amethistina is Simalia kinghorni now. Morelia carinata Rough-scaled python 2624 Python R2 R2 Morelia viridis Green python (Australian provenance) 2616 Python R2 R2 Oedura gemmata Dotted velvet gecko 2132 Gecko R2 R2 Pogona microlepidota Kimberley bearded dragon 2190 Dragon R2 R2 Pseudothecadactylus lindneri Giant cave gecko 2135 Gecko R2 R2 Ramphotyphlops nigrescens Blackish blind snake 2599 File & blind R2 R2 Rheodytes leukops Fitzroy river turtle 2045 Turtle/tortoise R2 R2 Rhynchoedura ornata Beaked gecko 2137 Gecko R2 R2 Saltuarius wyberba Granite leaf-tailed gecko 2851 Gecko R2 R2 Strophurus spinigerus South-west spiny-tailed gecko 2069 Gecko R2 R2 Tiliqua multifasciata Centralian blue-tongued lizard 2577 Skink R2 R2 Threatened species (V) Tiliqua occipitalis Western blue-tongued lizard 2579 Skink R2 R2 Threatened species (V) Tiliqua scincoides intermedia Northern blue-tongued lizard 5057 Skink R2 R2 Tropidonophis mairii Keelback snake 2629 Colubridae R2 R2 Tympanocryptis cephalus Blotch-tailed earless dragon 2253 Dragon R2 R2 Tympanocryptis cephalus has been split into 5 species, 4 of which have restricted distribution. The most widespread and one almost certainly kept in captivity is now named Tympanocryptis pseudopsephos . Keeping "Tympanocryptis cephalus on the list encourages poaching of these species.

Tympanocryptis lineata Lined earless dragon 2255 Dragon R2 R2 Tympanocryptis tetraporophora Long-tailed earless dragon 2257 Dragon R2 R2 Underwoodisaurus sphyrurus Border thick-tailed gecko 2139 Gecko R2 R2 Threatened species (V) Varanus baritji Black-spotted ridge-tailed monitor 2733 Monitor R2 R2 Varanus brevicauda Short-tailed pygmy monitor 2264 Monitor R2 R2 Varanus caudolineatus Line-tailed pygmy monitor 2265 Monitor R2 R2 Varanus giganteus Perentie 2267 Monitor R2 R2 Varanus glauerti Kimberley rock monitor 2269 Monitor R2 R2 Varanus indicus Mangrove monitor 2272 Monitor R2 R2 Varanus kingorum Pygmy rock monitor 2284 Monitor R2 R2 Varanus mertensi Merten's water monitor 2273 Monitor R2 R2 Varanus mitchelli Mitchell's water monitor 2274 Monitor R2 R2 Varanus panoptes Yellow-spotted monitor 2285 Monitor R2 R2 Varanus primordius Northern blunt-spined monitor 2276 Monitor R2 R2 Varanus rosenbergi Rosenberg's goanna 2287 Monitor R2 R2 Threatened species (V) Varanus scalaris Spotted tree monitor 2281 Monitor R2 R2 Varanus spenceri Spencer's monitor 2279 Monitor R2 R2 Varanus storri Storr's monitor 2280 Monitor R2 R2 Varanus varius Lace monitor 2283 Monitor R2 R2 Hoplocephalus bitorquatus Pale-headed snake 2675 Elapidae R3 R3 Threatened species (V) Hoplocephalus bitorquatus x stephensii Pale headed/Stephen's banded snake hybrid T161 Elapidae R3 R3 Hoplocephalus bungaroides Broad-headed snake 2676 Elapidae R3 R3 Threatened species (E) Hoplocephalus stephensii Stephen's banded snake 2677 Elapidae R3 R3 Threatened species (V) Parasuta spectabilis Spectacled hooded snake 2813 Elapidae R3 R3 Parasuta spectabilis spectabilis 5112 Elapidae R3 R3 Pseudechis collettii Collett's snake 2691 Elapidae R3 R3 Pseudechis porphyriacus Red-bellied black snake 2693 Elapidae R3 R3 Suta flagellum Little whip snake 2727 Elapidae R3 R3 Threatened species (V) Vermicella annulata Eastern bandy-bandy 2734 Elapidae R3 R3 Acanthophis antarcticus Southern death adder 2640 Elapidae R4 R4 Acanthohis praelongus Northern death adder 2804 Elapidae R4 R4 Acanthophis pyrrhus Desert death adder 2641 Elapidae R4 R4 Acanthophis wellsei Pilbara death adder 2833 Elapidae R4 R4 Austrelaps ramsayi Highlands copperhead 2615 Elapidae R4 R4 Austrelaps superbus Lowlands copperhead 2642 Elapidae R4 R4 Cryptophis nigrescens Eastern small-eyed snake 2650 Elapidae R4 R4 Denisonia maculata Ornamental snake 2662 Elapidae R4 R4 Notechis ater Black tiger snake 2680 Elapidae R4 R4 Notechis scutatus Mailand tiger snake 2681 Elapidae R4 R4 Pseudechis affinis 2694 Elapidae R4 R4 Pseudechis australis Mulga snake 2690 Elapidae R4 R4 Pseudechis butleri Spotted mulga snake 2814 Elapidae R4 R4 Pseudechis guttatus Spotted black snake 2692 Elapidae R4 R4 ingrami Ingram's brown snake 2696 Elapidae R4 R4 Pseudonaja modesta 2697 Elapidae R4 R4 Pseudonaja nuchalis Mulga 2698 Elapidae R4 R4 Suta suta 2722 Elapidae R4 R4 Oxyuranus microlepidotus Fierce snake 2689 Elapidae R5 R5 Oxyuranus scutellatus Taipan 2688 Elapidae R5 R5 Pseudonaja guttata Speckled brown snake 2695 Elapidae R5 R5 Pseudonaja textilis 2699 Elapidae R5 R5 Pseudechis weigeli T1041 Elapidae R5 R5 Tropidechis carinatus Rough-scaled snake 2723 Elapidae R5 R5 Proposed additions and changes to NSW Native Keepers’ Species List

Scientific Name Common Name Species Code Species Group Current Class Proposed Class Comment AM Proposed Code AM Feedback Comments and Reasoning Amphibolurus centralis Centralian Tree Dragon - New R1 R1 Should be a relatively easy to keep species. Most likely already kept as Lophognathus gilberti or Amphibolurus burnsi. Aprasia picturata Black-headed Worm-lizard 2853 New R1 Prohibited This species is known from less than 5 records from two tiny locations in . A handful of people are known to have even seen this species, and there is absolutely no legal way for it to be collected from WA. In addition to this Aprasia are very very hard species to keep with a high expert knowledge required.

Gehyra occidentalis Kimberley Plateau Dtella 2097 New R1 R1 Lerista allochira Cape Range Slider 2240 New R1 Prohibited Only one Lerista is currently on the NSW species list. This species (L. allochira ) is much smaller and more difficult to keep. Aditionally it is restricted to WA and cannot be legally kept. Morethia lineoocellata West Coast Morethia Skink 2528 New R1 Strophurus jeanae Southern Phasmid gecko 2010 New R1 R1 Strophurus wellingtonae Western Shield Spiny-tailed Gecko 2015 New R1 R1 Saltuarius moritzi Moritz Leaf-tailed Gecko 5182 New R1 R1 Already kept as Saltuarius swaini Emydura australis North-west Red Faced Turtle 2830 R2 R1 Emydura subglobosa Painted Short-neck Turtle 2036 R2 R1 Emydura tanybaraga Northern Yellow Face Turtle 2831 R2 R1 Emydura victoriae Northern Red-faced Turtle 2037 R2 R1 Calyptotis ruficauda Red-tailed Calyptotis 2031 New R2 R1 A fairly easy to keep and extremely common species in the wild. Chelosania brunnea Chameleon Dragon 2220 New R2 Ctenophorus clayi Black-collared Dragon 2179 New R2 Ctenophorus fordi Mallee Military Dragon 2185 New R2 Ctenophorus ornatus Ornate Dragon 2198 New R2 Ctenophorus salinarum Claypan Dragon 2207 New R2 Cyrtodactylus tuberculatus Cooktown Ring-tailed Gecko - New R2 Morelia Simalia oenpelliensis Oenpelli Rock Python 2626 New R2 Simalia kinghorni Scrub Python - New R2 This species is already on the list just under the name of Morelia amethistina. True Simalia amethistina are not naturally found in Australia and should not be allowed to be kept. What is being kept is Simalia kinghorni . IF keepers are actually keeping S. amethistina the source of these should be investigated and steps taken to remove them from captivity (Prohibit breeding etc).

Tympanocryptis centralis Centralian Earless Dragon 2904 New R2 Tympanocryptis intima Smooth-snouted Earless Dragon 2254 New R2 Varanus glebopalma Black-palmed Monitor 2270 New R2 Varanus hammersleyensis Southern Pilbara Rock Monitor - New R2 Varanus pilbarensis Pilbara Rock Monitor 2286 New R2 Varanus prasinus Emerald Monitor 2275 New R2 Prohibited Only known in Australia from a couple of islands off Qld. Adding these to the approved keeping list is likely to strongly encourage poaching, and potentially illegal import from New Guinea. Varanus semiremex Rusty Monitor 2278 New R2 Prohibited The main threat to this species is poaching, and there are many instances where the species has anecdotally been poached from the wild in large numbers. Addition of this species to the keepers list encourages this behaviour.

Demansia vestigiata Lesser Black Whipsnake 2652 New R3 Echiopsis curta Bardick 2667 New R3 Simoselaps minimus Dampierland Burrowing Snake 2811 New R3 Prohibited A highly range restricted snake, that is very difficult to keep with no legal collection from WA allowed. Pseudonaja aspidorhynchus Strap-snouted Brown Snake 5229 New R4 Acanthophis rugosus Papuan Death Adder - New R5 Acanthophis hawkei Plains Death Adder - New R5 Acanthophis lancasteri Kimberley Death Adder - New R5 Oxyuranus temporalis Western Desert Taipain 5180 New R5 Paraplocephalus atriceps Lake Cronin Snake 2806 New R5